[EAS] Should the RWT EAS Code be abolished?

[Clay Freinwald]

I have resisted jumping into this one for a while - (But no longer)

 

Here are some things to consider - 

 

This has been an interesting discussion, after giving the matter some 

Thought, perhaps a bit of history would be helpful

 

FCC, when they morphed EBS into EAS did not really create a new system

But rather made 'adjustments' to the old one.    

 

The biggest change (beyond replacing the B with an A) was to change 

Each local areas CPCS-1 to redundant facilities and re-name them LP1 

And LP2.  They then asked everyone to monitor two sources.  (They

Then called this a 'web architecture'...I would have used the word

redundant) Then everyone was to transmit a test once per week and 

each station, down-stream was to receive these two transmissions etc.

 

The FCC hung onto a couple legacy EBS methods - 

 

1 - THE DAISY CHAIN.   Even though the rules did not say we had to 

Continue to use this method of distribution, the Commish did not 

Provide guidance for much of anything else.   Accordingly, using  what

I called the 'Great Assumption' most states continued to use the 

Daisy Chain despite it being a 'lightning rod' for griped and grumbles

During the EAS era.  

 

2 - BROADCASTERS ARE THE ORIGINATORS OF EAS MESSAGES - 

It was unfortunate that the FCC did not spend more time in the 

Real-world (out of WDC)....Had they, they would have discovered

That those that have the emergency message info. should be the ones 

That initiate the messages...and NOT broadcast stations.    Again 

This was a carry -over from EBS where the procedure was for the 

Local Emergency manager, law enforcement etc to call the local 

Broadcast station asking them to 'tell the folks........"

 

It's unfortunate that the FCC failed to change the rest of their rules

For EBS/EAS to conform with one of the major reasons why they 

Made the change in the first place...UN-ATTENDED OPERATION

Of Broadcast Stations.    To some degree, the new rules were 

In conflict with the new procedures ....Rule Changes that took

us from EBS to EAS that were not fully thought Out.

 

The FCC, for the past almost 15 years, has had us all send RWT's

Based on the assumption that broadcasters were still the SOURCE

Of Public Warning Messages.....When in reality, they should not

Be for a number of reasons.  Lack of training and, of course, 

Unattended operation.

 

Here's an example - 

 

The MAJOR source of EAS messages is the NWS...And the majority 

Of those messages that get into the EAS and broadcast come directly 

>From NWR.   And yet ....The NWS is not asked tasked in the rules to

initiate RWT's or RMT's for that matter (Some states are the exception) 

 

This brings up another gripe of mine....In my view, testing of a

System should be- END TO END - and not a partial test of a portion 

Of a system.   I feel that those that initial EAS messages should be 

The sources of ALL  EAS Tests.   Again this is an EBS carry over where

Broadcasters were thought of as EAS Message originators.

 

The above was carefully considered by the State of Washington 

Many years ago and this is why ALL of the RMT's are generated by 

NWS, State and Local Emergency Mangement.   No broadcaster 

In this state initiates an EAS message.

 

Now we are rapidly entering the world of CAP.   And with this 

Change the realization that Broadcasters should not be the sources

Of EAS/Public Warning messages (unless there is a compelling reason) 

And, perhaps, one of the valid reasons for the elimination of the 

RWT placing it where it should be, in the dust bin of history along 

With EBS.

 

Here in Washington the State as well as all counties are now 

Generating their EAS tests as well as actual EAS messages using our 

CAP based system....The State EOC generates RMT's, RWT's, DMO's 

Etc all using CAP.    (Yes, they also use the legacy analog equipment 

And will do so until the conversion to CAP is complete) 

 

If we are to have RWT's in the future, my vote is to have ALL of 

These tests generated by the Sources of EAS/Public Warning 

Messages on a rotating basis so that, over a period of time, all 

Source entities have had their turn, thereby enhancing the

Positive training aspect of the act.   (Yes we do that now here) 

 

It will require a good deal of courage for the FCC to finally put an

End to the broadcasting of these weekly tests and to do so, it 

Will require that the FCC finally put an end to the daisy chain, 

Once and for all.     The change to CAP will make this possible 

As all stations (Radio, TV and Cable) will then be fed in Parallel 

As opposed to in series (ala the Daisy Chain).

 

When this change is compete, the RWT, which is nothing more 

Than a partial test of the Daisy Chain, will  become pointless

And un-necessary.

 

So much for my view from Washington State...and about 40 

Years working with various systems.

 

Clay Freinwald